Document evqb91YBExpr03XxE6oq8D1gy

REDACTED LIBERTY MUTUAL 2 Executive Campus, P.O. Box 5343, Cherry Hill, New Jersey 08002 Tel. (609) 663-9121 November 10, 1981 Sherwin-Williams Company 101 Prospect Avenue NW Cleveland, OH 44115 RE: t - SHERWIN-WILLIAMS FILE NUMBER: CE 327-15881 - SHERWIN-WILLIAMS FILE NUMBER: CE 327-19930 ATTENTION: THOMAS M. LOCKER, ADMINISTRATOR OF WORKER'S COMPENSATION Dear Mr. Locker: Enclosed you will find a carbon copy of our Attorney Edwards' letter of November 5, 1981. Also enclosed is a copy of a Request For Production of Documents. i You will note from Mr. Edwards' letter that he asks that you contact his office as soon as possible concerning this request. Thank you in advance for your kind cooperation in this matter. Very ^trulv yours A S.E. Barton Claims Supervisor SEB:hi Enc. ////#/&/. Mr ///s *9e>r/t>su /S <$>e/A/6 /Z/e/ej r:^ C&O'/STT JT rocZ> u/**? "swc Re c e iv e d NOV 18 1981 H//CC a/>7~///aS6 e/A/776 M/gT <*& S? Tt( Sr#*} c^cce-C Fk r?wcl N40366 LIBERTY MUTUAL INSURANCE COMPANY LIBERTY MUTUAL FIRE INSURANCE COMPANY * LIBERTY LIFE ASSURANCE COMPANY OF BOSTON HOME OFFICES: BOSTON ,1 ARTHUR MONTANO JAMES A. MULLEN,JR. F. HERBERT OWENS, HI ROBERT. EDWARDS ROBERT T. ZANE ALAN P. BRUCE ... ALFRED P.VITARELLI GLENN F. CALLAHAN PAUL F. G1LLIGAN, JR. LAW OFFICES MONTANO. SUMMERS, MULLEN & MANUEL A PROFESSIONAL CORPORATION WILLIAM W. SUMMERS G. WESLEY MANUEL, JR. CARL J. GREGORIO GARY L. JAKOB F. MICHAEL DAILY, JR. MICHAEL J. WEISS BERNARDJ. TKACZYNSKJ LAWRENCE D. LALLY TIMOTHY J. HIGGINS SUITE 420 - TWO EXECUTIVE CAMPUS ROUTE 70 & CUTHBERT BLVD. CHERR/ Y HILL. NEW JERSEY 08002 November 5? 1981 CARL KISSELMAN {1899-1975) TELEPHONE AREA &m `09 665-6800 PLEASE REFER TO OUR FILE: Liberty Mutual Insurance Company 2 Executive Campus F. O. Box 5343 Cherry Hill, Hew .Jersey 08092 5 610 ~E a t t n : He. s. *. Barton. REDACTED tet ....V. The Sherwin-Williams Company, et al, Your File Nos,~E33f~l5881 and C1327-19930 Dear Mr. Barton: 0 .inclosed are copies of a Notice .of Motion brought by Archer? :eier & Bead on behalf of' John iueas & Company ? as'a division of V |he Sherwin-Williams company? to dismiss the Complaint in the aboveQ' ' :ioned matter based upon the Workmen's Compensation Statute* filed an identical motion, both of which are returnable oh fCwd / November 20? 1981, Additionally, we enclose copies of the Request Production of Documents, which has been served upon us, ' I/would. jest that this Request immediately be forwarded to The fin-Williams Company and that they be advised to contact''my office . irning this Request , The document production appears to be lengthy may require some additional time to answer, Of eoursd, if our :ion to dismiss this Complaint is successful on November 20? 1981, there will be no need to produce the documents? at least until such as a subpoena is served upon The Sherwin-Williams Company for them & Please be advised that we have now filed our Answer? which has been executed by John B. Kearney as counsel for The Sherwin-Williams Company as to punitive damages only? with the Court in this matter. ?e enclose our invoice in' the amount of $40.09 for the cost of filing same with the Court. We shall keep you further advised. Very truly yours, ' ' 9D3R MONTANO, SOMMERS? MULLEN & MANOIL A Professional corporation iter e m JJiH YRR3HO REE t hi Eaes. Robert E. Edwards N40366 01 0007-S WP-005806010 CONFIDENTIAL